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In 2012, UK medical devices maker Smith & Nephew plc resolved a $22 million FCPA enforcement action concerning conduct in Greece. According to the DOJ, “from 1998 to 2008, Smith & Nephew, its affiliates and employees authorized the payment of approximately $9.4 million to the distributor’s shell companies, some or all of which was passed on to physicians to corruptly induce them to purchase medical devices manufactured by Smith & Nephew.”

Smith & Nephew recently disclosed that it is again under FCPA scrutiny, and is “investigating allegations of possible violations of anti-corruption laws in India and responding to related requests for information from the SEC.”

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